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MAY 22, 2013
Chairman Barletta, Ranking Member Norton, Members of the Subcommittee:
Thank you for the opportunity to discuss the Nuclear Regulatory Commission’s (NRC) efforts to
reduce office space consistent with the Federal Freeze the Footprint policy.
NRC was established in 1975 as an independent Federal agency to license and regulate the
Nation’s civilian use of byproduct, source, and special nuclear materials to ensure adequate
protection of public health and safety, promote the common defense and security, and protect
the environment. As such, we regulate the safety of all 102 operating nuclear power plants, and
over 5,000 nuclear materials, medical, industrial, and fuel cycle licensees in the United States.
To fulfill its responsibility, the NRC performs the following regulatory functions: develops
regulations and guidance for applicants and licensees; licenses or certifies applicants to use
nuclear materials or operate nuclear facilities; regulates the decommissioning of facilities;
inspects and assesses licensee operations and facilities to ensure that licensees comply with
NRC requirements and takes appropriate follow-up or enforcement actions when necessary;
evaluates operations experience of licensed facilities and activities; and conducts research,
holds hearings, interfaces with domestic agencies and international partners, and obtains
independent reviews to support regulatory decisions. Many of these functions require special
facilities, such as: secure hearing spaces, emergency response centers, technical and law
libraries, a public document room, public meeting facilities, and numerous collaborative
Importance of Collocation
The Three Mile Island nuclear accident demonstrated the need for collocation of NRC’s diverse
headquarters staff to sustain NRC’s operational efficiency, regulatory effectiveness, and
emergency response capability. At that time, the NRC headquarters staff was housed in more
than ten buildings located in the D.C. metropolitan area. Following that accident, the
President’s Commission on the Accident at Three Mile Island, headed by John Kemeny,
strongly recommended the collocation of headquarters staff. These recommendations were
recently reinforced by NRC’s experience and that of Japan’s in responding to the Fukushima
nuclear accident. As observed by NRC technical experts, Japan experienced challenges in
coordinating its response efforts that stemmed from a regulatory infrastructure dispersed across
multiple ministries and agencies in several locations throughout Tokyo. NRC also experienced
challenges in coordinating its support to Japan because of the dispersion of NRC staff experts
in multiple Montgomery County, Maryland, locations.
NRC’s initial consolidation of its headquarters began in 1986 with the General Services
Administration’s (GSA) acquisition of the One White Flint North (1WFN) building. At the time of
the 1WFN building acquisition, GSA and the NRC agreed that a contract would be entered into
by GSA and the lessor (White Flint North LLP) to construct, build, and lease Two White Flint
North (2WFN) for purposes of housing the remainder of NRC headquarters employees on one
campus. In order to fully integrate the two buildings, the 2WFN building was constructed with
surface and sub-surface connectors to 1WFN. Collocation of NRC headquarters staff was
achieved in 1994 with the completion of the 2WFN building. In recent years with the growth of
the NRC staff, the NRC has had to lease additional space in four different buildings in the
Bethesda-Rockville area. Some of this growth was driven by the need to enhance the securityrelated regulatory framework for NRC licensees following the terrorist attacks of 9/11.
In 2006, a potential nuclear power resurgence was stimulated by projected demands for
increased electricity and national policy initiatives contained in the Energy Policy Act of 2005,
such as loan guarantees from the Department of Energy. The NRC’s projection for applications
to construct new, nuclear power plants jumped significantly in FY 2007. The rapid pace at
which applications were submitted had an immediate impact on the structure and workload of
the agency. In response to the increased workload, the NRC ultimately projected its
headquarters staff would need to be augmented substantially. As a result, the NRC pursued a
third building.
On December 26, 2007, the President signed appropriations law (P.L. 110-161) that included a
specific provision for the NRC to obtain additional office space collocated with its headquarters
buildings in order to maintain NRC’s regulatory effectiveness, efficiency, and emergency
response capability. GSA signed the lease for Three White Flint North (3WFN) on October 23,
In the years it has taken to design, construct, and lease Three White Flint North (3WFN), the
NRC staffing has increased, but not to the level originally expected. As a result of economic
factors and revised business plans of applicants, the number of new license applications under
consideration has tapered and NRC’s staff growth commensurately stabilized in response.
Concurrent with these developments, the Federal government has instituted new guidelines for
utilization of real estate. A Presidential Memorandum issued in June 2010 and the Office of
Management and Budget (OMB) Management Procedures Memorandum issued on March 14,
2013, set new guidelines for space utilization within Federal buildings.
Soon after arriving at the NRC in the summer of 2012, NRC Chairman Macfarlane became
aware of office space issues, including concerns from the Subcommittee on Economic
Development, Public Buildings, and Emergency Management regarding the renewal lease
prospectus for 2WFN.
Upon learning of these concerns, the Chairman took immediate action by chartering a task force
of senior staff to take a thorough look at space utilization and cost estimates. The Chairman
charged this task force with delivery of a comprehensive, integrated, and updated business
case that rebaselined the space requirements and campus cost profile to achieve both footprint
reductions and target utilization rates for office space.
The NRC is committed to ensuring that the agency’s footprint is the right size to sustain NRC’s
mission, is cost effective, and is consistent with the Administration’s space utilization policies.
To further that objective, NRC has been working intensively with GSA on developing a building
consolidation solution that is designed to address issues identified by the Subcommittee.
Importantly, the NRC Chairman and the Acting GSA Administrator met and subsequently
chartered teams that have worked jointly and diligently over the past 5 months to evaluate the
NRC’s updated business case and develop the financial analysis to support a recommendation
to this Committee. The teams have considered a range of scenarios. The resulting housing
analysis concludes that even with a reduced utilization rate, the NRC needs approximately two
and a half buildings to house NRC staff and perform its functions. The optimal approach for
meeting these NRC housing needs is to retain 2WFN in its entirety and for the NRC to
relinquish several floors in 3WFN for use by another Federal tenant.
The NRC’s preferred path forward is consistent with the Freeze the Footprint policy and
achieves targets for space utilization set forth in OMB guidelines. The plan is also consistent
with the agency’s goal to consolidate its headquarters staff on one campus without adversely
affecting the agency’s safety and security mission responsibilities, while providing effective
working conditions for the agency’s predominately professional, engineering, and scientific
workforce, and providing a working environment that will allow it to recruit and retain a highly
qualified, primarily technical, workforce.
Rationale for Maintaining 2WFN
If the lease prospectus is not renewed and the NRC were to vacate 2WFN, the agency would
have insufficient space to house its current employees and conduct effectively its nuclear safety
mission. A two-building campus consisting of 1WFN and 3WFN would result in an office
utilization rate of approximately 100/sf, a utilization rate that is more typically associated with
organizations whose employees work predominantly outside of an office (in the field).
Government organizations with a large number of professional level, scientific, and engineering
staff whose work requires a significant amount of in-office work require significantly more
Additionally, vacating 2WFN in its entirety will require NRC to give up mission-critical specialuse space that is needed to support various activities required by law, including the Atomic
Safety and Licensing Board Panel hearing room, the Advisory Committee on Reactor
Safeguards rooms, and the NRC Technical Library. The Atomic Safety and Licensing Board
Panel hearing room is specially constructed for conducting hearings regarding licensing actions,
including those of a security-sensitive nature, that are pending before the NRC. The statutorily
required Advisory Committee on Reactor Safeguards necessitates special space for the conduct
of meetings, often involving sensitive, proprietary, and security-related information to review
significant NRC licensing actions. The costs incurred in the construction and configuration of
these special-use spaces in 2WFN would be lost were the lease not renewed. As these are
mission-critical facilities, new costs would have to be incurred with the construction of
replacement facilities, including configuration necessary to meet security standards
(Underwriters Laboratories 2050 certified) for security-sensitive hearings.
Vacating 2WFN would also result in the NRC giving up valuable joint use space such as the
Government child care facility that was designed and constructed to meet specific siting and
licensing requirements. The child care center cannot be replicated in either 1WFN or 3WFN
because sufficient space is not available to provide a secure outdoor play area or easy access
to a child care facility. Displacement of children from the 2WFN building, and the effect on NRC
employees, and other federal employees who use the center, should be taken into account.
NRC and GSA analysis concludes that there are significant financial, logistical, and securityrelated issues associated with leasing a portion of 2WFN. If the NRC were to share occupancy
of 2WFN with another tenant, for security reasons, measures would need to be taken to provide
for viable ingress and egress to the 2WFN building. As stated earlier, 1WFN and 2WFN
currently share multiple surface and sub-surface connectors; as currently configured vehicle
ingress is entirely via 1WFN and vehicle egress is entirely via 2WFN. In light of the security
requirements that apply to the NRC, if another tenant were to occupy 2WFN, measures would
need to be taken to provide for segregation of the buildings and viable entrances for each tenant
would be required. According to GSA preliminary estimates, it would cost approximately $16.4
million and take approximately 54 months, to separate 1WFN and 2WFN to address logistical
and security concerns. Separating the buildings would require the demolition, redesign, and
reconstruction of numerous above- and below-ground connections and building systems, the
renegotiation of easements, Montgomery County approval of a revised site plan, and new
security installations between 1WFN and 2WFN.
According to GSA, the Government will be financially responsible for paying rent for all space in
2WFN regardless of whether it is occupied in whole or in part by the NRC, for the entire 54month time period, because additional occupants could not be permitted until renovations
required by the lease and the new tenant are completed. Consequently, any vacant floors in
2WFN will be unmarketable for that period. For the above stated reasons, partial occupancy of
2WFN is not cost-effective to the NRC, the Government, or taxpayers.
The joint analysis by NRC and GSA of available options for right-sizing the NRC campus
footprint and minimizing costs suggests that the optimal approach is to retain a campus
consisting of 1WFN, 2WFN, and part of 3WFN.
The 3WFN building is a certified silver building under the U.S. Green Building Council’s
Leadership in Energy and Environmental Design Program and capable of multi-occupancy
tenancy. The 3WFN building is more marketable to potential tenants than 2WFN because it is
new construction adjacent to a Metro station. Additionally, 3WFN can better sustain level 4
security standards with multiple tenants at lower costs as compared to 2WFN because there will
be no need to incur building separation and ingress creation costs that would be required if NRC
were to vacate or relinquish space in 2WFN.
In closing, I want to reiterate NRC’s commitment to being responsive to the Freeze the Footprint
initiative, our changing space needs, and the Subcommittee’s interest in its efforts to right-size
the Government’s foot print in a cost-effective and timely manner. We will continue to work with
GSA, OMB, and Congress in order to identify a solution that accomplishes these objectives
while optimizing the use of the NRC campus in a manner that maintains NRC’s regulatory
effectiveness, efficiency, and emergency response capability. We will continue to address
these issues fully and transparently. We look forward to working with this Committee on this
important matter.
I would be happy to answer any questions you may have.